Wyoming Statutes

Wyo. Stat. § 27-14-608 (2026)

Attorney fees; penalty for violation.

✓ current as of May 2026

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     (a) If the hearing examiner under W.S. 27-14-602(d) or the
district court or supreme court under W.S. 27-14-615 set a fee
for any person for representing a claimant under this act
excluding a health care provider, the person shall not receive
any additional fee from the claimant.

     (b) Any person violating this section is guilty of a
misdemeanor and upon conviction shall be fined not more than
seven hundred fifty dollars ($750.00), imprisonment in the
county jail for a term not to exceed six (6) months, or both.

Notes of Decisions

Cited in 19 cases, 1991–2015 · leading case: Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001).

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Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001). · cites it 12× “On appeal, the Office of Administrative Hearings (OAH) denied the claim on two grounds: (1) the claimant failed to establish his heart condition met the statutory requirements of Wyo. Stat. Ann. § 27-14-608 (b) (LexisNexis 2001), 2 and (2) the claimant failed to establish a…”

Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). · cites it 8× “Ball suffered the hernia when a spinal cord stimulator, implanted to treat chronic back pain from an earlier compensa-ble work-related injury, malfunctioned and shocked him, causing him to stand rapidly and then fall, The question we must answer is whether the hernia occurred…”

Worker's Comp. Claim of Newman v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2002 WY 91 (Wyo. 2002). “§ 27-14-102(a)(xi) (LexisNexis 2001) and an injury which occurred over a substantial period of time pursuant to § 27-14-608(a). In reaching this determination, the hearing examiner found Ms.”

Carabajal v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 119 P.3d 947 (Wyo. 2005). · cites it 2× “Due to the perceived lack of a work-related triggering event for the 1997 injury, the hearing examiner applied the burden of proof set forth in Wyo. Stat. Ann. § 27-14-608 (a) regarding injuries which develop over a substantial period of time.”

State ex rel. Wyoming Workers' Comp. Div. v. Brown, 805 P.2d 830 (Wyo. 1991). · cites it 8× “W.S. 27-14-608 (1987). This section was also restated in 1989 by amendment obviously intended to delete the supervision of fees charged by the health care provider by stating: (a) If the hearing examiner under W.”

Serda v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2002 WY 38 (Wyo. 2002). · cites it 4× “[2] We include here Wyo. Stat. Ann. § 27-14-608 (LexisNexis 2001), which prohibits an attorney from receiving an additional fee from a claimant.”

KG Constr., Inc. v. Sherman, 2005 WY 116 (Wyo. 2005). · cites it 2× “[117] Section 27-14-608(a) establishes five separate elements a claimant must prove to establish an injury occurring over a substantial period of time.”

Horn-Dalton v. State, 2009 WY 14 (Wyo. 2009). · cites it 2× “This testimony supports the conclusion that Appellant's injury occurred over a substantial period of time and is subject to the heightened burden of proof of Wyo. Stat. Ann. § 27-14-608 (a) (LexisNexis 2007), which states as follows: (a) The burden of proof in contested cases…”

State Ex Rel. Wyoming Workers' Saf. & Comp. Div. v. Garl, 2001 WY 59 (Wyo. 2001). “§ 27-14-608(a) (LEXIS 1999) reads: (a) The burden of proof in contested cases involving injuries which occur over a substantial period of time is on the employee to prove by competent medical authority that his claim arose out of and in the course of his employment and to prove…”

Frontier Refining, Inc. v. Payne, 2001 WY 49 (Wyo. 2001). · cites it 2× “*41 [¶10] Because Payne claimed that his CTS occurred over a substantial period of time, the hearing examiner applied Wyo.Stat. Ann. § 27-14-608(a)(1) through (v) (Lexis 1999): Burden of proof; required proof of circumstances; coronary conditions; hernia.”

Chavez v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 204 P.3d 967 (Wyo. 2009). · cites it 2× “Chavez relies on, Wyo. Stat. Ann. § 27-14-608 (3), explicitly requires a claimant to prove that the injury occurring over time was caused by the conditions of his work.”

Harris v. Sinclair Trucking, 900 P.2d 1163 (Wyo. 1995). · cites it 2× “Whether the administrative conclusion that Sherman Harris’ heart attack was not compensable under the standards of W.S. § 27-14-608 is supported by substantial evidence, in accordance with law and not arbitrary, capricious or an abuse of discretion.”

Show all 19 citing cases →

— Wyo. Stat. § 27-14-608(0) — 1 case

Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). “Ball suffered the hernia when a spinal cord stimulator, implanted to treat chronic back pain from an earlier compensa-ble work-related injury, malfunctioned and shocked him, causing him to stand rapidly and then fall, The question we must answer is whether the hernia occurred…”

— Wyo. Stat. § 27-14-608(a) — 5 cases

KG Constr., Inc. v. Sherman, 2005 WY 116 (Wyo. 2005). “[117] Section 27-14-608(a) establishes five separate elements a claimant must prove to establish an injury occurring over a substantial period of time.”

Johnson v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 166 (Wyo. 2010).

Robinson v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2009 WY 47 (Wyo. 2009).

— Wyo. Stat. § 27-14-608(a)(1) — 1 case

Frontier Refining, Inc. v. Payne, 2001 WY 49 (Wyo. 2001). “*41 [¶10] Because Payne claimed that his CTS occurred over a substantial period of time, the hearing examiner applied Wyo.Stat. Ann. § 27-14-608(a)(1) through (v) (Lexis 1999): Burden of proof; required proof of circumstances; coronary conditions; hernia.”

— Wyo. Stat. § 27-14-608(b) — 2 cases

Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001). “On appeal, the Office of Administrative Hearings (OAH) denied the claim on two grounds: (1) the claimant failed to establish his heart condition met the statutory requirements of Wyo. Stat. Ann. § 27-14-608 (b) (LexisNexis 2001), 2 and (2) the claimant failed to establish a…”

Sheth v. State ex rel. Wyoming Workers' Comp. Div., 11 P.3d 375 (Wyo. 2000).

— Wyo. Stat. § 27-14-608(b)(f) — 1 case

Scherf v. State ex rel. Dep't of Workforce Servs., 360 P.3d 66 (Wyo. 2015).

— Wyo. Stat. § 27-14-608(b)(ii) — 1 case

In the Matter of the Worker's Comp. Claim of: Anita J. Fieseler v. State of Wyoming ex rel. Wyoming Workers' Saf. & Comp. Div., 2013 WY 116 (Wyo. 2013).

— Wyo. Stat. § 27-14-608(c) — 1 case

— Wyo. Stat. § 27-14-608(c)(ifi) — 1 case

— Wyo. Stat. § 27-14-608(c)(iii) — 1 case

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